---
title: "DMA designation intake workflow for gatekeeper notifications"
canonical_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/designation-intake-workflow"
source_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/designation-intake-workflow"
author: "Sorena AI"
description: "Build a grounded DMA designation intake record covering core platform service classification, Article 3 thresholds, Form GD evidence, Commission handoff, and Article 11 readiness."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Digital Markets Act"
  - "DMA gatekeeper designation"
  - "Form GD"
  - "core platform service"
  - "Article 3"
  - "Article 11"
  - "DMA"
  - "gatekeeper designation"
---
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---

# DMA designation intake workflow for gatekeeper notifications

Build a grounded DMA designation intake record covering core platform service classification, Article 3 thresholds, Form GD evidence, Commission handoff, and Article 11 readiness.

*Workflow* *EU DMA*

## DMA gatekeeper designation intake workflow

Use this workflow before a DMA gatekeeper notification to classify each candidate core platform service, test Article 3 thresholds, assemble Form GD evidence, and prepare the Commission handoff.

Designed for competition counsel, regulatory operations, finance, analytics, product owners, and compliance teams that need one evidence record before filing or escalation.

The DMA designation intake should answer a narrow question: does an undertaking provide one or more core platform services that trigger Article 3 gatekeeper notification or Commission assessment? The intake record should separate each service, preserve the data used for threshold calculations, capture any substantiated arguments, and hand a complete package to the team responsible for Form GD and later Article 11 compliance planning. Timings in this page are source-linked; verify current legal source language before implementation decisions.

## 1. Open one intake row per candidate core platform service

Start by classifying the service against the DMA's closed list of core platform service categories. The intake should not treat a platform group, brand, app bundle, or business unit as one undifferentiated service if the DMA analysis depends on the service category and user calculation.

Record the service name, legal undertaking, product owner, business model, Member States where the service is provided, and whether the same service is provided in at least three Member States for the Article 3(2)(a) presumption.

- Classify the candidate service as online intermediation, search, social networking, video-sharing, number-independent interpersonal communications, operating system, web browser, virtual assistant, cloud computing, or qualifying online advertising service.
- For integrated services, record why they are one service or distinct services; the DMA Annex warns against splitting services mainly by domain names or geographic attributes.
- Capture product and analytics contacts who can explain user counts, logged-in and logged-out usage, business accounts, duplicate handling, and outlier months.
- Check the Commission's public gatekeeper page only as a status reference for existing designations; do not use it as a substitute for the undertaking's own Article 3 intake.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Article 2 lists the core platform service categories and Article 3 links designation to the specific services listed in the designation decision.
- [European Commission - DMA gatekeepers page](https://digital-markets-act.ec.europa.eu/gatekeepers_en?ref=sorena.io) - Use this public Commission page to verify whether an undertaking or service is already listed as designated, amended, or repealed.

## 2. Test Article 3 designation triggers before drafting Form GD

The intake should show whether the undertaking meets the DMA Article 3(1) gatekeeper requirements directly or is presumed to meet them under Article 3(2). Keep the legal test and the data calculation separate so reviewers can see exactly which fact supports each limb.

If all quantitative thresholds are met, Article 3(3) requires notification to the Commission without delay and in any event within two months after the thresholds are met. The same two-month intake trigger applies when a further core platform service of an already designated gatekeeper meets the relevant user thresholds.

- Internal-market impact: annual Union turnover of at least EUR 7.5 billion in each of the last three financial years, or average market capitalisation or equivalent fair market value of at least EUR 75 billion in the last financial year, plus the same core platform service in at least three Member States.
- Gateway scale: at least 45 million monthly active end users established or located in the Union and at least 10,000 yearly active business users established in the Union in the last financial year.
- Entrenched position: the Article 3(2)(b) user thresholds were met in each of the last three financial years.
- Qualitative path: if the quantitative thresholds are not all met, preserve facts relevant to Article 3(8), including users, network effects, data-driven advantages, scale and scope effects, lock-in, vertical integration, and other structural service characteristics.
- Exceptional arguments: if the undertaking meets all quantitative thresholds but argues that Article 3(1) is not satisfied, prepare the substantiated arguments as a separate annex rather than mixing them into the threshold worksheet.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Article 3 provides the gatekeeper requirements, quantitative presumptions, two-month notification trigger, Commission designation timing, qualitative assessment route, and service-listing effect.
- [Commission Implementing Regulation (EU) 2023/814 - Form GD](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Article 2 requires Article 3(3) notifications to contain the information and documents indicated in Form GD, including any Article 3(5) substantiated arguments in an annex.

## 3. Build the Form GD evidence intake package

Once the Article 3 trigger is credible, convert the intake into a filing package. The evidence package should be complete enough for Form GD review but still traceable back to the service-level intake rows.

Assign one owner for each evidence class: corporate and finance data, service classification, user measurement, business-user methodology, territory coverage, exceptional arguments, signatures, confidentiality, and Commission communications.

- Corporate evidence: undertaking identity, group structure, contact details, legal representatives, and power of attorney where external representatives are used.
- Financial evidence: Union turnover for the relevant financial years, market capitalisation or fair market value analysis, and the source systems or public filings used for each figure.
- Service evidence: description of each candidate core platform service, category rationale, Member State coverage, service boundaries, and integration with other services.
- User-count evidence: monthly active end users, yearly active business users, unique-user methodology, logged-in and logged-out measurement approach, duplicate controls, and treatment of outlier figures.
- Argument evidence: a separate annex for any Article 3(5) arguments that the undertaking does not satisfy Article 3(1) despite meeting Article 3(2) thresholds.
- Submission readiness: confirm language, format, page-limit handling, confidentiality claims, QES signatures for Form GD and power of attorney, and a named Commission communication owner.

Sources for this answer:

- [Commission Implementing Regulation (EU) 2023/814 - Form GD](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - This implementing regulation sets the Form GD notification framework, effective-date rules, format requirements, and annex route for Article 3(5) arguments.
- [European Commission - DMA practical information](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io) - Commission practical information confirms submission formatting, language expectations, and that Form GD and power of attorney documents sent digitally need a qualified electronic signature.
- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - The DMA Annex provides the methodology context for active end-user and active business-user calculations used in Article 3 threshold evidence.

## 4. Hand the designation package to Commission-facing owners

Before submission, run a handoff meeting with competition counsel, the filing owner, analytics, finance, product, and compliance. The goal is to confirm that each Form GD claim can be traced to an approved dataset, source, or annex.

The handoff record should also cover what happens if the Commission requests information, issues preliminary views, rejects weak substantiated arguments, opens a market investigation route, or designates the undertaking based on information available to it.

- Handoff packet: final service list, threshold worksheet, methodology note, evidence index, confidentiality log, signatory list, power-of-attorney status, and Commission contact owner.
- Completeness check: each service meeting Article 3(2)(b) has its own user-count support and each exceptional argument has an annex owner.
- Timing check: the record identifies when the thresholds were met and whether the Article 3(3) two-month notification window has been triggered.
- Response readiness: keep owners available for Commission information requests, corrections to incomplete data, and observations on preliminary views.
- Decision capture: when a designation decision is adopted, record the undertaking, each listed core platform service, designation scope, and the date from which Article 3(10) compliance planning is measured.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Article 3 explains the Commission's 45-working-day designation period after complete information, designation based on available information, and listing of relevant core platform services.
- [Commission Implementing Regulation (EU) 2023/814 - Form GD](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - This source supports handoff controls for notifications, submissions, effective dates, format and length rules, and communication with the Commission.

## 5. Prepare Article 11 readiness as soon as designation risk is real

Designation intake should not end at filing. Article 3(10) gives designated gatekeepers six months after a core platform service is listed in a designation decision to comply with Articles 5, 6, and 7, and Article 11 requires a compliance report within six months after designation plus at least annual updates.

Use the intake to open an Article 11 readiness backlog for every service likely to be listed. The backlog should connect each DMA obligation to product measures, implementation dates, geographic scope, supporting data, internal documents, metrics, privacy or security justifications, and a non-confidential summary track.

- Create one Article 11 planning row per core platform service and per applicable Article 5, 6, or 7 obligation.
- Record whether each compliance measure was already in place before designation or needs post-designation implementation.
- Collect evidence for product, service, device, and geographic scope; technical and engineering changes; APIs or operating-system functionality where relevant; internal data policies; security measures; and metrics used to assess effectiveness.
- Keep the full methodology for any analysis, testing, or survey that will support the compliance report.
- Track non-confidential summary drafting in parallel so confidential information decisions do not delay the public-facing summary required by the Commission template.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Article 3(10) links designation to the six-month compliance period for Articles 5, 6, and 7; Article 11 establishes the compliance-report obligation.
- [European Commission - Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - The Commission template explains the minimum information expected in Article 11 compliance reports, including service-by-service annexes, supporting data, internal documents, and non-confidential summaries.

*Recommended next step*

*Placement: before sources*

## Use this workflow to prepare a DMA designation handoff

Use the cited sources listed here to verify obligations and the supporting evidence requirements.

- [Open Research Copilot for DMA designation](/solutions/research-copilot.md): Verify the following areas from the cited sources:  Article 3 thresholds, Form GD evidence, and Article 11 readiness using the cited DMA sources on this page.
- [Talk through DMA designation intake](/contact.md): Review a candidate service list, evidence gaps, Form GD handoff, and post-designation readiness plan with Sorena.

## Primary sources

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Primary legal source for DMA core platform service categories, Article 3 designation criteria, thresholds, notification timing, Commission designation decisions, and Article 11 readiness triggers.
  - Quote: "Designation of gatekeepers"
- [Commission Implementing Regulation (EU) 2023/814 - Form GD](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Source for the Form GD notification procedure, required notification contents, substantiated-argument annex, format and length rules, and procedural communication requirements.
  - Quote: "FORM RELATING TO THE NOTIFICATION"
- [European Commission - DMA practical information](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io) - Commission practical page for submission format, language, templates, power of attorney support, and QES signature expectations for Form GD and related documents.
  - Quote: "Signing documents electronically"
- [European Commission - DMA gatekeepers page](https://digital-markets-act.ec.europa.eu/gatekeepers_en?ref=sorena.io) - Commission public status page for checking current gatekeeper and core platform service designations after an internal intake has identified a relevant undertaking or service.
  - Quote: "Gatekeepers"
- [European Commission - DMA legislation and templates](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission page that hosts DMA procedural materials and templates, including the Article 11 compliance report template used for post-designation readiness planning.
  - Quote: "Article 11 DMA - Compliance Report Template Form"

## Related Topic Guides

- [DMA Anti-Circumvention Design Review for Gatekeeper Product Changes](/artifacts/eu/digital-markets-act/anti-circumvention-design-review.md): Review DMA Article 13 anti-circumvention risks in gatekeeper product, interface, contractual, commercial, and technical changes with obligation mapping and evidence records.
- [DMA Article 11 Compliance Report Template FAQ](/artifacts/eu/digital-markets-act/faq/compliance-report-template.md): How gatekeepers should use the DMA Article 11 compliance report template to document obligation-by-obligation measures, evidence, updates, and non-confidential summaries.
- [DMA Article 6 Business User Data Access Guide](/artifacts/eu/digital-markets-act/business-user-data-access.md): Grounded guide to EU Digital Markets Act Article 6 data access for business users, end users, authorised third parties, consent boundaries, and evidence handoffs.
- [DMA Article 6(7) and Article 7 interoperability obligations](/artifacts/eu/digital-markets-act/article-6-7-interoperability.md): Grounded guide to DMA interoperability duties: Article 6(7) operating-system feature access, Article 7 messaging interoperability, request handling, security conditions, and compliance evidence.
- [DMA Articles 5, 6 and 7 obligations mapped to CPS evidence](/artifacts/eu/digital-markets-act/core-obligations-by-obligation.md): Map EU Digital Markets Act Articles 5, 6 and 7 obligations to affected core platform services, product evidence, legal owners, and Article 11 compliance-report artifacts.
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- [DMA Core Platform Service Scoping](/artifacts/eu/digital-markets-act/core-platform-service-scoping-by-service.md): Scope EU Digital Markets Act core platform services by service category, designation evidence, user thresholds, and Form GD service-boundary records.
- [DMA core platform services FAQ](/artifacts/eu/digital-markets-act/faq/core-platform-services.md): FAQ on EU Digital Markets Act core platform services: Article 2 service categories, gatekeeper designation evidence, user thresholds, service scoping, and Article 11 reporting.
- [DMA CPS Obligation Matrix Workflow: Articles 5, 6, 7 and Article 11 Evidence](/artifacts/eu/digital-markets-act/cps-obligation-matrix-workflow.md): Build a DMA core platform service obligation matrix that links each designated CPS to Articles 5, 6 and 7 duties, product owners, designation evidence, Article 11 report artifacts and review gates.
- [DMA enforcement, penalties, and remedies: Commission powers and evidence](/artifacts/eu/digital-markets-act/enforcement-penalties-and-remedies.md): EU Digital Markets Act enforcement guide covering Commission non-compliance decisions, DMA fine caps, periodic penalty payments, remedies, interim measures, commitments, and Article 11 evidence.
- [DMA Gatekeeper Compliance Checklist for Articles 5, 6, 7 and 11](/artifacts/eu/digital-markets-act/gatekeeper-compliance-checklist.md): A grounded EU Digital Markets Act checklist for designated gatekeepers: core platform service scope, Article 5/6/7 controls, Article 11 report evidence, anti-circumvention checks, and review gates.
- [DMA Gatekeeper Designation Guide: Article 3 thresholds, Form GD, and Article 11 readiness](/artifacts/eu/digital-markets-act/gatekeeper-designation-guide.md): A grounded EU Digital Markets Act guide for assessing Article 3 gatekeeper thresholds, scoping core platform services, preparing Form GD evidence, handling rebuttal annexes, and planning Article 11 compliance reporting.
- [DMA gatekeeper thresholds: what counts and when to notify](/artifacts/eu/digital-markets-act/faq/gatekeeper-thresholds.md): Standalone FAQ on the EU Digital Markets Act gatekeeper thresholds, Article 3 notification timing, Form GD evidence, and active user-count methodology.
- [DMA interoperability requests: Article 7 and Commission guidance](/artifacts/eu/digital-markets-act/faq/interoperability-requests.md): How EU Digital Markets Act interoperability requests work for Article 7 messaging services, Article 6(7) operating-system access, gatekeeper evidence, requester evidence, and security safeguards.
- [DMA penalties and fines: caps, triggers, and enforcement evidence](/artifacts/eu/digital-markets-act/penalties-and-fines.md): EU Digital Markets Act penalties guide covering Article 30 fine caps, Article 31 periodic penalty payments, non-compliance decisions, remedies, and evidence records.
- [DMA Product Change Review Workflow for Articles 5, 6, 7, 11 and 13](/artifacts/eu/digital-markets-act/product-change-review-workflow.md): Review DMA-relevant product releases for Article 5, Article 6, Article 7, anti-circumvention, Article 11 evidence, and product-owner/legal signoff.
- [DMA Self-Preferencing Compliance Examples for Ranking and Display](/artifacts/eu/digital-markets-act/self-preferencing-compliance-examples.md): Examples and release-review controls for DMA Article 6(5) self-preferencing checks across ranking, indexing, crawling, search results, marketplaces, app stores, feeds, and virtual assistants.
- [DMA vs Data Act: gatekeeper duties compared with EU data-sharing rules](/artifacts/eu/digital-markets-act/dma-vs-data-act.md): Compare the EU Digital Markets Act and EU Data Act by scope, actors, data access, interoperability, reporting, evidence, and enforcement without merging distinct obligations.
- [DMA vs DSA: Digital Markets vs Services Act](/artifacts/eu/digital-markets-act/dma-vs-dsa.md): A grounded comparison of the DMA and DSA focused on gatekeepers, core platform services, DMA obligations, Article 11 reporting, interoperability, data access, and enforcement.
- [DMA vs EU competition law: gatekeeper obligations, Article 11 evidence, and enforcement](/artifacts/eu/digital-markets-act/dma-vs-eu-competition-law.md): Compare the EU Digital Markets Act with EU competition law: ex ante gatekeeper and core platform service duties, Articles 5 to 7, Article 11 reports, penalties, and evidence records.
- [DMA vs GDPR: gatekeeper data obligations compared](/artifacts/eu/digital-markets-act/dma-vs-gdpr.md): Compare DMA gatekeeper obligations with high-level GDPR overlap for consent, combining personal data, data access, portability, and Article 11 reporting.
- [EU Digital Markets Act Article 11 Evidence Calendar](/artifacts/eu/digital-markets-act/annual-report-evidence-calendar.md): Build a source-grounded DMA Article 11 compliance report calendar with evidence owners, annual update checkpoints, report sections, and review gates.
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- [EU Digital Markets Act compliance: gatekeeper obligations and evidence](/artifacts/eu/digital-markets-act/compliance.md): DMA compliance guide for designated gatekeepers: core platform service scoping, Articles 5, 6 and 7 controls, Article 11 reports, anti-circumvention checks, interoperability evidence, and enforcement risk.
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- [EU DMA Article 11 Compliance Reporting Guide](/artifacts/eu/digital-markets-act/article-11-reporting.md): Source-grounded guide to EU Digital Markets Act Article 11 compliance reports: report purpose, template evidence, non-confidential summaries, annual updates, and submission steps.
- [EU DMA do's and don'ts for product teams](/artifacts/eu/digital-markets-act/dos-and-donts-for-product-teams.md): Product release checks for designated DMA gatekeepers: Article 5, 6 and 7 obligations, anti-circumvention review, data access, interoperability, self-preferencing and Article 11 evidence.
- [What do DMA Articles 5, 6, and 7 require from gatekeepers?](/artifacts/eu/digital-markets-act/faq/articles-5-6-and-7-obligations.md): FAQ explaining how EU Digital Markets Act Articles 5, 6, and 7 group gatekeeper obligations, what product evidence they require, and how Article 11 reporting connects.


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